More than two decades ago, Sleeter (1987) challenged the commonly accepted notion that the category of Learning Disabilities (LD) was established as a natural consequence of the culmination of advances in medical knowledge. Instead, she argues that the emergence of LD served a sociopolitical purpose by distinguishing failing white middle class students from minorities and lower class students when the United States called upon its schools to raise standards during the Cold War era. In reframing the field's origin story, Sleeter reconceptualizes the ontological nature of LD as a social construct, rather than as an abnormal, biological condition. Yet currently, the field remains steeped in medicalized conceptualizations of disability. Despite nebulous neurological explanations and "subjective, if not capricious" (Harry, Klingner, Sturges, & Moore, 2002, p. 86) diagnostic processes, individuals operating from the dominant educational paradigm support reification of LD as an intrinsic deficit. Alternatively, scholars from a Disabilities Studies in Education (DSE) perspective contend that what constitutes ability or disability lies not within the individual, but in the discursive practices of our schools (Reid & Valle, 2004). What is problematic in framing the individual as the unit of analysis is that it leaves unexamined the contextual influences that shape how individual differences are interpreted as deviances (Gabel, 2005; Varenne & McDermott, 1998).

Reflecting on Sleeter's arguments underscores the formidable tasks we face in contemporary contexts. Despite the fact that the LD category initially served the interest of white middle class students, culturally and linguistically diverse (CLD) students have been overrepresented in special education for more than 30 years (Donovan & Cross, 2002), an issue Sleeter presciently warned as a potential problem in her article. Conceptualizing LD as a social construct is significant considering that disproportionate representation of CLD occurs in high-incidence special education categories, such as Mental Retardation, Emotionally Disturbed, and LD, but not in the low-incidence disability categories, such as visual, auditory, or orthopedic impairments (Donovan & Cross, 2002; Parrish, 2002). As Donovan and Cross argue, the significance of this finding is that high-incidence categories rely on the judgments of school personnel, underscoring the significance of school contexts in the identification process. Referrals for LD evaluations often begin in the classroom, as teachers identify students who do not perform to expectations. When differences are interpreted as deviances, students are more likely to be subjected to reductionistic, watered-down instruction, due to lowered expectations (Ellis, 1997). Furthermore, intersections of race, class, language proficiency, and disability compound the difficulties disabled students face. For students who are negotiating mismatches between their cultural backgrounds and the dominant culture, decontextualized approaches targeting specific areas of weakness may further alienate students.

Parallels between the sociopolitical context of the 1960s and current conditions also give cause for concern. Similar to the Cold War era, today the United States hopes to rebuild its political and economic status in the world. Moreover, and once again, public schools face an intensive standards-based reform. Low-performing, high-poverty schools, often populated by CLD students endure the most intense scrutiny, along with highly prescriptive curriculums (Sleeter, 2005). While part of this focus is to address the inequities that exist among different demographics, standardizing practices can marginalize and alienate those who are not from the dominant culture. Furthermore, students from low socioeconomic status backgrounds do not have access to the same learning opportunities as their more privileged peers. Thus, the additional label of LD compounds the multiple inequities such students face.

In understanding LD as a discursive phenomenon that is constituted through interactional processes, it becomes pertinent to examine the discourses that are currently circulating in schools. An important legacy of Sleeter's work is to move beyond the individual locus and broaden the unit of analysis to examine the conditions in which ability/disability take form. In addition, one of the critiques of DSE is its leanings toward theory while neglecting actual practice (Gabel, 2005). Thus, to glean insights from classroom practices, I present examples drawn from an eight-month ethnographic study focusing on the classroom discourses1 in three 8th grade collaborative team teaching (CTT) classes.2 The public school is located in an urban setting and deemed "low-performing" as measured by standardized tests. Ninety-four percent of the students qualify for free or reduced lunch. Demographically, 79% of the students in this school are Asian/Pacific Islander, 12% of the students are Hispanic, 7% of the students are black, and 2% of the students are white3. The teachers included in this paper are Ms. Amy,4 the special education teacher for ELA and social studies, Ms. Erin, the ELA general education teacher, and Mr. Bradshaw, the special education teacher for math and science. All teachers are white and in their late twenties.

Dominance of the Medical Discourse

It is not surprising that medicalized conceptualizations of LD are ubiquitous in schools, considering that special education arose from the disciplines of medicine and psychology. In Sleeter's (1987) article, she posits three reasons why the organic basis of LD resonated with parents and professionals at the inception of the field: 1) it implied the disability was "curable," 2) it offered a reason for academic difficulties without implicating the parents, and 3) it hierarchically distinguished LD from MR, thus diminishing the stigma attached to the new category. The notion remains widely accepted in the dominant educational discourse today, in part, because it has become naturalized by many as an undisputed fact. But belief in disability as an innate condition also serves specific functions, as Mr. Bradshaw expresses:

Interestingly, Mr. Bradshaw not only conceptualizes LD as a "neurological deficiency," but he also perceives students' lived experiences through the lens of science (e.g., "the amygdala is literally shut down" when students have "emotional deficiencies"). His purposes for situating students' performances and experiences in the brain appear to be twofold: to legitimize differences among students and to establish the legitimacy of the "expert" knowledgebase of special education (for fear of being "dismiss[ed.]"). His hopes of persuading teachers to consider students' circumstances seem sensible enough. But arguments that attribute undesirable performances of CLD students to innate characteristics contribute to a deterministic and deficit-oriented line of thinking, thereby marginalizing the students (Collins, 2003). Yet in evoking the medical discourse, variances are conceptualized as deviances. As Mr. Bradshaw describes, students have "deficiencies or something that…they don't have that we have." In distinguishing "we," the normal population, from those with physiological issues, he reinforces our hierarchical system and establishes the inferiority of such students, all the while with the intention of helping students learn.

As the interview continues, Mr. Bradshaw reveals how his epistemological beliefs undergird his faith in science:

Mr. Bradshaw characterizes his ideas as a "philosophy," but when Ms. Amy challenges the neurological explanations for LD, he immediately counters with brain-based research, relying on the empiricism of brain scans to justify his epistemological beliefs. He is able to ask indignantly, "How is it not real?" in part because of the legitimacy and neutrality the scientific discourse maintains in our society. From conversations with both teachers throughout the year, they clearly understood that contextual elements contribute to students' learning. Yet despite their awareness, both function in the dominant special education discourse in which the "breakdown" resides within the individual. The unit of analysis for the "where the real problem is" (italics added) remains within the biological makeup of the student.

The "hard way," that Ms. Amy refers to, entails assessing students' learning processes, noting their areas of strengths and weaknesses. Part of Levine's (2002) assessment5 approach focuses on cultivating strengths in individuals, which is undoubtedly useful. But efforts to understand students' strengths are undermined if the cause of learning difficulties is attributed to the individual, discouraging teachers to reflect on the conditions that allow such difficulties to exist in the first place. Moreover, by offering students the hope of being "rewired" to succeed in school, Levine leaves the system of meritocracy intact; his message is that LD students, equipped with strategies, will be able to compete self-sufficiently with their peers. Levine's popularity lies in the fact that this rhetoric of individual remediation is in harmony with the central role individualism plays in the United States (Dudley-Marling, 2004). With the focus on personal responsibility, the promise of success seems achievable without the need to interrogate whether success for all is truly attainable in our hierarchical system (Brantlinger, 2004). It is simpler for schools to participate in professional developments that center on individual remediation, rather than address the ableist underpinnings of our educational system. As such, the special educators draw upon pedagogical approaches that align with such beliefs, as discussed in the next section.

Reliance on Behaviorism and Authoritarian Oversight

Operating from the understanding that a disability is a condition to be cured, special educators often approach instruction as remediation, drawing upon authoritative and behaviorist principles:

Interestingly, both educators perceive authoritative teaching to be necessary, despite their unease with the approach. Although Mr. Bradshaw recognizes that his "kids aren't learning anything if you approach them like that," he presumes top-down approaches would be effective "for the majority" of "this population." Similarly, Ms. Amy, who does enact such practices in her classes, believes "you just have to be like that" even though she does not "like being like that." As such, both teachers ignore their own intuitions and experiences, and instead, draw upon the commonly held notion that disabled students from low-income, CLD backgrounds require a strict, disciplinary approach. In doing so, the teachers unconsciously position such students as inferior and illustrate beliefs reminiscent of the ones held by white middle class parents who sought to distinguish their children from the culturally deprived (Sleeter, 1987). The unchanging underlying assumption that poor, CLD students are deficient grounds their implementation of behaviorist principles in the classroom. While Ms. Amy often expressed her desire to foster students' independence and not "baby" them anymore, her use of authoritative powers to control the class counters such intentions. The "behavior management plan" Mr. Bradshaw refers to is a rewards system in which the class is awarded a prize (e.g, pizza party) when they fill a jar with marbles for good behavior. Reward/punishment systems may alter students' behaviors in the short-run, but they fail to engender meaningful, lasting transformations in students as learners (Smith, Danforth, & Nice, 2005). As Smith et al. (2005) argue, for some students, such practices are at odds with their lives outside of school. Indeed, it seems simplistic to assume prizes could motivate students in this class, who are facing issues related to poverty and gangs. Instead of encouraging students to learn, authoritative practices, along with an infantilizing perspective (i.e., referring to students as "babies") evoke various forms of resistance in students, as revealed by a number of disabled students in this class who voiced their resentment towards Ms. Amy's scrutiny and domination. While her intention was to encourage student participation, she, in fact, silences them and makes them feel "like…her target," as an LD student remarked.

Ms. Amy often puts forth great effort to engage students, but with her attention on remediating students' weaknesses, she unconsciously positions them as disabled, highlighting their inadequacies in front of the whole class. For instance, Ms. Amy often called on disabled students to repeat the last directions given or the new concepts covered, as the following excerpt illustrates:

Hao Yu's responses were inaudible, and only those looking directly at him were able to decipher the words he mouthed. Ms. Amy's intention was to facilitate Hao Yu's engagement, but her approach unnecessarily positioned him as disabled by creating a situation which provoked him to withdraw rather than participate willingly. She often posed fill-in-the- blank type questions, assuming they are easier to answer, but at times, such formats appear more difficult than open-ended questions since they limit the possible acceptable responses from students. Perhaps without feeling the pressure of having the entire class wait for his response, Hao Yu could have answered some of Ms. Amy's questions. Such positionings caused his peers to describe him as someone who "learns slower than others," "doesn't get it as well," "has problems learning," "needs more time to learn," and "needs a microphone." In contrast to his interactions during nonacademic moments, he was considerably more tentative and "disabled."

As the special educator, Ms. Amy characterizes her role as working "behind the scenes" to "break...down" the lessons and help general educators "understand how I want it to be taught for the special ed." She explains that she teaches the lessons when they pertain to her "expertise like grammar or assessment." Such notions correspond with the traditional divide between general and special education: general educators are responsible for content-based designs, while special educators focus more on skills and individual needs (Daunci, Correa, & Reyes-Blanes, 2004). In Ms. Amy's description of her responsibilities, she implies that she possesses specialized knowledge in how to teach disabled students which general educators lack. Ms. Erin concurs that their collaboration has shifted the ways in which she pays attention to how students learn:

Ms. Erin interprets this form of intervention as "active engagement," but from a DSE perspective, it is deficit-oriented, as previously discussed. Ms. Erin's reflection highlights that while the appropriation of existing special education knowledge by general educators could help enrich teachers' practices, it could also perpetuate inequitable and marginalizing practices. Problematically, Ms. Amy and Mr. Bradshaw both draw upon the special education discourse, enacting authoritative practices that attribute problems to students' "neurological deficienc[ies]" and are deficit oriented (e.g., assigning and isolating disabled students to individual seats while the rest of the class sat in groups, or when Ms. Amy realized that an LD student rarely spoke in class, she "started basing her grade mostly on participation" to motivate her). As Allan (2006) critiques, "Much of the work required in teacher education is an unraveling of the existing special needs knowledge base and opening students up to difference as complex and interesting rather than as something to be managed. They need to be veered away from knowledge about students' pathologies…" (p.355). Considering the limitations teachers may place on students when they operate from the mechanistic paradigm (see Heshusius, 2004), the potential knowledge sharing and epistemological adoption of special education discourse by general education teachers raise serious concerns.

Deconstructing Learning Disabilities

Ms. Erin's revelation of what she had learned from Ms. Amy is especially concerning in light of her own pedagogical approach, which often positioned students as capable and competent readers and writers, as she demonstrates in the following example. In the excerpts, Pedro (LD) is revising his short story in a conference with Ms. Erin. Prior to the meeting, Pedro was clearly anxious as he repeatedly muttered, "My writing is horrible. My writing is horrible." His story, entitled "The Secret of My Life," describes the day when the protagonist, Jay, reveals to his mother that he is gay. The narrative is based on Pedro's own experience; his sexual orientation is not a topic he discusses openly, nor does he hide it. His engagement in this writing process was evident from beginning to end. At Pedro's request for privacy, the conference took place in the hallway:

In this exchange, Ms. Erin positions Pedro as a capable writer as she encouraged him to self-edit during the revision process. While reading aloud, Pedro demonstrates that his ability to reflect on his work. He clarified sentences (e.g., adding in "to her" in the sentence, "Jay saw Melody at her locker so he runs up to her…") and reflected on word choices (e.g., "tells" is more specific than "said" since it indicates an audience). Thus, Pedro reveals he was actively thinking about his text and not simply waiting for Ms. Erin to correct his writing.

Throughout the conference, Ms. Erin posed questions as a reader asking for clarification, rather than as an authoritative voice. In doing so, she foregrounds the meaning of his text rather than her knowledge:

In this example, Ms. Erin couched her questions in terms of clarifications, rather than corrections, allowing the meaning of the text to drive the editing process (e.g., "as a reader, I'm thinking, 'Hmm. When did this happen?'"). Instead of instructing Pedro to add a transition word, she pondered aloud to communicate how a reader might interpret his text. Her questions serve as scaffolds to guide his process of elaboration. When she addressed writing conventions, she connected the meaning to the form. (e.g., "so that's why you indented," linking indenting a new paragraph to a change in setting). In explaining why he hates writing, Pedro identified "check[ing] grammar and spelling" to be particularly discouraging. He also expressed dislike for the lack of control over his writing (e.g.,"…like you have to um fix it. And sometimes you want it that way but then they say, 'No, you put it this way…'"). In this conference, however, he did not appear to be impatient with the revisions, but was thoroughly engaged in the process. Perhaps in wondering her ideas aloud, Ms. Erin conveyed to Pedro that revision is not a matter of "fixing" his writing, but of clarifying his intentions. Their exchange reveals that when students are invested in the topic, the tedium of the mechanical aspects of writing diminishes.

Ms. Erin's perception of Pedro's agency as a writer is also evident, as the excerpt below illustrates:

Throughout the conference, Ms. Erin drew upon a variety of pedagogical approaches, showing instances of explicit instruction and moments guided by constructivist beliefs. Regardless of her approach, her respect for Pedro as a writer was evident. Even in the more teacher-directed moments (e.g., when she instructed Pedro to match the pronoun to the noun), she offered him the opportunity to make the final decisions. Furthermore, the conference did not focus solely on correcting grammar, as remediation-oriented instruction often can be for disabled students. Ms. Erin balanced her critiques with numerous substantive praises. Rather than simply offer generic compliments, such as "good job," she grounded her comments in the specifics of his written accomplishments, as when she commended him on being a "sophisticated writer" for painting a vivid description of the mother's reaction and asking readers to "make all these inferences."

Perhaps most telling of Pedro's engagement in this process was his comment to me after the conference — his plan to write a "chapter two" to the story. In stark contrast to the fierce loathing he expressed towards writing during our interview prior to this unit, his remark provides evidence that when students genuinely connect with a topic, writing issues associated with LD — lack of stamina, motivation, and difficulty initiating a topic — become less of a problem. Often in the traditional LD discourse, writing difficulties are presented as a constellation of "symptoms" stemming from students' disabilities. For instance, Hallahan et al. (2005) list the following characteristics: LD students "produce writing with errors in spelling, capitalization, punctuation, and handwriting," "lack effective skills for revising writing," "use less complex sentence structures and include fewer types of words," "write paragraphs that are less well organized," "include fewer ideas in their written products," and "write stories that have fewer important components, such as introducing main characters, setting scenes, describing a conflict to be resolved" (p.428-429). For those who operate from the dominant medical discourse, such difficulties are often interpreted as manifestations of students' innate disabilities. However, Pedro illustrates that reluctant students are able to write cogently when conditions for engagement are in place. Arguably, his short story exhibits "thematic maturity," coherent organization, and insightful descriptions of the characters, settings, and conflicts because he was able to exercise authentic ownership of his writing. While his story does contain non-Standard American English usage, writing conventions are learned skills that require practice, not necessarily biological flaws that are representative of students' abilities. As the conference illustrates, it is easier for students to practice such skills within contexts that encourage them to invest whole-heartedly in the process of writing.

Ms. Erin's practices contrast Ms. Amy's authoritative approaches and foreground the potential limitations when educators perceive specialized knowledge to be essential to educating disabled students. At a time when standardizing ideologies permeate so many aspects of schooling, it is essential to explore other possibilities — alternatives that allow space for the art of teaching/learning to be flexible and adaptive enough to respond to the dynamics of each class. In addition to examining the circumstances in which LD is constructed, moments in which disability is deconstructed, when students' potentials are cultivated, are significant to understand as well.

Conclusion

Sleeter (1987) asserts, "School structures are created and used by someone to serve the interests of someone with a particular context…[The creation of the LD category] was not accomplished by a top-down mandate, but by parents and educators who were attempting to make the best possible life for their children within a social context they accepted" (p.233). That the dominant LD discourse remains relatively unchanged in its conceptualizations of LD (i.e., the ontological nature of the disability and how the field emerged) indicates that such notions continue to serve the purposes of invested parties. In addition to the sociopolitical forces Sleeter describes, the field has grown into an established discourse that sustains the (re)production of such beliefs, as the teachers in this article illustrate. Mr. Bradshaw draws upon the scientific discourse to help general educators understand student variances, but also utilizes its assumed legitimacy to address the unequal power relations among general and special educators. While possessing honest intentions of helping students to learn, Ms. Amy does not recognize how the epistemological and ontological underpinnings she draws upon from the special education discourse actually position students as disabled. As Gallagher (2004) asserts:

In the case with learning disabilities, as long as we are confined to the metaphors of discovery, the only possibility open to us is to continue in an endless search for that elusive, and unfortunate, deficiency within the individual. Also, educators are closed off from examining their practices, choices, and expectations that may be creating the conditions that result in "seeing" the disability in the first place (p.13).

In light of the long-standing issue of overrepresentation of minorities in special education, it is concerning how both special educators consider behaviorist and authoritative approaches to be necessary and beneficial for this population. Sleeter (1987) proposes that the creation of the category served to "maintain race and class stratification" (p.233), and she points out the increasing classification of minority students as LD. Her foresight underscores the significance of examining how the category functions within different contexts and how it perpetuates racial/cultural and class inequities by subjecting "deprived" students to normative standards and practices.

The examples reveal that context matters in the construction of LD, reaffirming Sleeter's arguments. Systemic attempts to categorize students' diversity according to race/ethnicity, ability, linguistic proficiencies, and so forth, obscure the fact that students who are categorically the same harbor different life experiences, all of which significantly influence their learning in the classroom. Labels, which in essence name students' inabilities, offer little guidance for educators; in fact, they may influence teachers to intentionally or inadvertently set limits on the learning opportunities for these students. In contrast to the dominant special education paradigm, DSE perspectives can offer teachers a different discourse — to understand variances as ordinary and natural, and thus, engage with educators in examining potential disabling conditions, rather than trying to justify why human differences exist. This broadened unit of analysis may help to shed light on the complexities of learning that defy categorical assumptions of students, and thus challenge the foundations professionals often draw upon to identify and educate disabled students. In understanding the contexts in which disabilities are constructed/deconstructed, the focus is on what students can achieve and respositions disabled students as individuals with agency (Gabel, 2005). Ultimately, dismantling exclusionary practices and institutions require ongoing examination of how we affirm the potential of our students.